Information We Collect and How We Use It
We collect information about you in these ways:
(I) Information You Provide: When you use Jetty’s website, including applying for an insurance product or loan, you will generally be required to provide personally identifying information, which may include your email address, name, address, telephone number and Social Security Number, as well as financial information, which may include income, employment and bank account information. We may also collect information about your home or apartment, such as the terms of any mortgage or lease, the type and location of your home or building and its construction, your living situation, the value of your home and your personal property, and your claims history. You may also have to provide certain documents to verify the information you provide.
(II) Information from Third Parties: Third parties, such as credit bureaus and bank account verification services, may provide us with information on you, including your credit score and transaction history. We may combine this information with information we already have about you to evaluate your insurance or loan application, to create or offer personalized products and services for you, or for similar purposes.
(III) Information from Your Use of the Website: We may collect additional user behavior information during your use of the website. This may include device information (such as your internet protocol address), log information (such as pages visited), location information (such as your geographical location), and other information (such as cookies and anonymous identifiers).
(IV) Information from our Property Management partners: Our property management partners may provide us with additional personal data in relation to your application and use of the Jetty Rent product. This may include information such as your payment history and lease details.
How We Use Information We Collect
Information we collect from you may be used in one or more of the following ways:
- To provide you with products and services, including in determining your eligibility for an insurance product or loan
- To verify your identity and age as well as to guard against potential fraud
- To obtain, where we have a permissible purpose or with your authorization, third-party data from credit bureaus or others in connection with your insurance or loan application
- To personalize your experience using the website
- To provide customer service
- To enable our service providers to provide you with services, such as funds transfers, billing, payments, and collection activities as needed
- To send you regular communications, including information and updates pertaining to your insurance policy or loan as well as news, updates, and related product or service information
- To improve our products and services and identify, develop or offer new products and services
- For our marketing purposes to offer our products and services to you
- To enforce agreements with you
- To comply with our legal obligations and any court order, law, or legal process, including retaining personal data or responding to any government or regulatory request
- To fulfill any other purpose for which you provide it or otherwise give your consent
We will retain your information for as long as needed to provide you services or as necessary to comply with our legal obligations and our backup, archival and audit procedures.
Cookies and Pixel Tags are sets of information or data that our servers assign to your device when you visit the Site, and which identify you as a unique user.
Information Sharing with Joint Marketers and Third Party Service Providers
Jetty may share information we collect to our partner properties or to other entities with whom we have joint marketing arrangements. Jetty may also share information relating to the use of our website with our analytics, social media, and advertising partners.
Do We Share Your Information with Others?
While we may share aggregate, de-identified and/or technical usage information with others such as through cookies, pixels, or other online tracking technologies, we will not share, rent, or sell your personal information with or to any unaffiliated third parties for their own marketing purposes or, except as permitted by law, for such unaffiliated parties own uses. All financial companies need to share their customers’ information, including personal information, to run their everyday business. We may share your information with non-affiliated parties for our everyday business purposes and as permitted by law, including processing transactions, maintaining accounts, and reporting to consumer reporting agencies. The information we may disclose about you depends on the products and services you have with us, and includes the information described in the Information We Collect and How We Use It section above. We may share information with third parties in the course of running our business, including:
- Underwriting and other business partners as part of delivering your coverage under our Insurance products or during the Claims handling process for any of our Insurance products
- The creditor who originates all the loans for our Jetty Rent product, currently Cross River Bank (Cross River Bank’s Privacy Notice can be found here) and any investor(s) who purchase your loan
- Service providers who assist with parts of our operations, such as loan servicers, technology providers, payment processing providers, credit bureaus, collections agencies, and other service providers
- Credit bureaus to report account information for Jetty Rent borrowers, as permitted by law
- Financial companies that we work with to jointly offer products and services
- Companies that we plan to merge with or be acquired by or who may provide us with financing, or companies we plan to sell, divest or transfer all or a portion of our assets, products and/or services to, including as part of a bankruptcy or insolvency proceeding
- Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedure or we need to do so to comply with law
- Companies that help us facilitate and/or improve the Site or Services, website analytics, or for other purposes that support our legitimate business activities, including providing you with special deals and discounts through our Jetty Member Benefits Program
- Our affiliate companies may receive information about your transactions and experiences with us for their everyday business purposes. Our affiliates include financial and nonfinancial companies with the Jetty brand.
- Other third parties but only if you consent or direct us to do so
We do not, however, share your personal information with the business partners that provide the special deals and discounts for our Jetty Members for their own marketing purposes. If you redeem any deals and discounts, you may directly provide your information to those third parties, and Jetty is not responsible for the activities or privacy practices of those third parties.
Federal and state laws allow you to restrict the sharing of your personal information in certain instances such as sharing your information so that third parties can market to you. However, because we will not share your information in these instances, there is no need for you to opt-out from this kind of information sharing. If you are a California or Vermont resident, then we will only share your information as permitted by law.
When you are no longer our customer, we continue to share your information as described in this notice.
Links to Third-Party Websites
The website may also contain links to websites that are not controlled or operated by us. This policy does not apply to such third-party websites and Jetty is not responsible for the content of such websites or the privacy practices of the third parties controlling or operating such websites. We encourage you to request and review the privacy policies of any third parties before disclosing your information to such parties or visiting such third-party websites.
How Do We Protect Your Information?
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and device by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Protection of Privacy for Minors
Our Services are solely for persons aged 18 and older and we take the privacy of minors very seriously.
If we learn that Personal Information has been collected from persons under the age of 18 on or through the Services, we will take the appropriate steps to erase this information. Also, if it comes to our attention that a registered user is a child under 18 years of age, we will cancel that user's account and/or access to the Services.
IF YOU ARE UNDER THE AGE OF 18, YOU MAY NOT USE OR ACCESS OUR SERVICES OR OUR SITE.
Compliance with State and Federal Laws
Your California Privacy Rights
Information for California consumers on the California Consumer Privacy Act (“CCPA”)
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the CCPA. The CCPA gives California residents rights described below with respect to their personal information.
Your Right to Request Disclosure of Information We Collect and Share About You
We collect the following categories of personal information: identifiers (such as your email address, name, address, telephone number and Social Security Number), property information (such as terms of any mortgage or lease, the type and location of your home or building and its construction, your living situation, the value of your home and your personal property, and your claims history), credit bureau information (such as your credit information from one or more credit bureaus), financial information (such as income, employment and bank account information, documents (such as documents to verify the information you provide), product information (such as products purchased from us and your payments on those products), internet or other activity information (such as browsing behavior, geolocation, IP address) and interactions with customer service, claims and collections (such as phone calls and emails). For more details about the personal information we collect and purposes we use it, please see the “Information we collect and how we use it” section above. We share this information with the categories of third parties described in the “Do We Share Your Information with Others?” section above.
Subject to certain exemptions, the CCPA provides California consumers the right to request to know more details about the categories and specific pieces of personal information we collect, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. If your information falls into one of the legal exemptions included in the CCPA, we may be unable to fulfill your request.
California consumers may make a rights request by emailing us at email@example.com or calling us toll free at 855-695-3889 Your Right To Request Deletion of Personal Information We Have Collected About You.
Upon your request, we will delete the personal information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law, or where the data is subject to an exception, such as the exception for information subject to the financial privacy law, the Gramm-Leach-Bliley Act (GLBA). Much of the information we collect is in the context of providing consumer financial services and is subject to this exception. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
Your Right to Request We Not Sell Personal Information
We do not sell personal information except as defined under the CCPA in the context of cookies and other tracking technologies that support our advertising and analytics activities. You may opt-out using the resources described in the section “About Cookies, Tags and Other Tracking Technologies” above.
Global Privacy Control
We also recognize opt-out signals communicated through the browser-based extension offered through the Global Privacy Control, a non-profit that is in the process of developing a technological tool that can be used universally to signal a user’s privacy preferences. However, please note that, due to the technical limitations of the Global Privacy Control’s extension, requests made through their extension apply only to the device on which the request is made (e.g., a specific computer) and will only work with the browser used to activate the opt-out setting (e.g., Duck Duck Go).
Our Commitment to Honoring Your Rights
Exercising Your Rights and How We Will Respond
For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
For requests to stop the sale of your personal information, we will comply no later than 15 business days after receipt of your request.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Verification of Identity – Access or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
Ensuring Veracity of Opt-Out Requests
If we have a good-faith, reasonable belief that a request to opt-out of the sale of personal information is fraudulent, we may deny the request. Should this occur, we will inform you and explain why we believe the request is fraudulent.
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will be required to provide us with proof of the agent’s identity and proof that you gave the agent signed permission to submit a request on your behalf. Additionally, you will be required to verify your identity by providing us with certain personal information as described above or provide us with written confirmation that you have authorized the agent to act on your behalf.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for Household Information
There may be some types of personal information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household personal information must be made by each member of the household. We will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.
California Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our website does not respond to browsers’ do not track signals.
International Privacy Rights
This Policy is current as of the Last Updated Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site Accessibility.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at firstname.lastname@example.org or 855-695-3889.
How You Can Contact Us
You may email us at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you have questions or concerns regarding this policy, please contact us by emailing us at firstname.lastname@example.org.